Walter L. Medlin - Page 170

                                       - 95 -                                         
          Mr. Medlin’s Tucker bank account No. 1089234 dated April 8, 1987,           
          shows the deposit of a check for $90,000 from “Orl. Land &                  
          Investment”, “LESS CASHIERS CHECK in the amount of $22,260.00”;             
          this resulted in a net deposit of $67,740 to account No. 1089234.           
               On April 6, 1987, petitioner executed a promissory note for            
          the benefit of Don Henry and Sylvia Cohn, which provided:                   
               90,000.00                                      4/6/1987                
               Ninty (90) days after date, the undersigned, for value                 
               received jointly and severally promise to pay to the                   
               order of Don Henry and/[illegible entry] Sylvia Cohn at                
               Orlando Fla.   Ninty Thousand ($90,000) + Twenty                       
               Thousand ($20,000) dollars with interest from date at                  
               the rate of ----% per annum until fully paid.  Interest                
               payable ----.  This note shall bear interest from                      
               maturity at the rate of ----% per annum until fully                    
               paid.                                                                  
          The promissory note is signed by petitioner.  Don Henry was the             
          president of Orlando Land & Investment Co.                                  
               Respondent determined that the deposit of $67,740 was                  
          taxable as income to petitioner for 1987.                                   
                                       OPINION                                        
               Petitioner contends that the deposit of $67,740 on April 9,            
          1987, represents a portion of the loan proceeds received from Don           
          Henry of the Orlando Land & Investment Co.                                  
               Respondent agrees that “The source for the deposit was a               
          check for $90,000 from Orlando Land & Investment”.  Accordingly,            
          the April 9, 1987, deposit is not unidentified as respondent                
          originally determined.  Nevertheless, respondent argues that this           






Page:  Previous  85  86  87  88  89  90  91  92  93  94  95  96  97  98  99  100  101  102  103  104  Next

Last modified: May 25, 2011